Memorandum Opinion
HOYT, Judge:
The respondent determined a deficiency of $12,161.13 for the year 1953. The remaining issues are whether certain properties sold by the petitioner were sold to customers in the ordinary course of business and, if so, whether one of the sales involved the sale of real estate or capital stock.
Some of the facts have been stipulated and are so found.
The petitioner, Sylvester A. Lowery, resides at 8200 Stenton...
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